This guide notice alerts grantees to a change in the implementation timeline, previously announced in NOT-OD-13-112, for the NIH transition to new U.S. Department of Health and Human Services (HHS) payment policies for grant awards and use of Payment Management System (PMS) subaccounts.

NIH will transition all award payments to the PMS subaccounts by the end of FY 2015. To help minimize grantee burden for the transition in FY 2014, NIH will only establish PMS subaccounts for domestic awards that have new document numbers. However, in response to feedback from the grantee community, NIH has delayed the implementation for non-competing continuation awards to October 1, 2014, to allow grantees a year to prepare their systems to accommodate the changes.

This Guide Notice only applies to domestic awards. NIH transitioned the payment of grant awards to foreign institutions to PMS subaccounts throughout FY 2013; see NOT-OD-12-139 and NOT-OD-13-019. Also, see companion Notice NOT-OD-13-111 on transitioning payment of Federal Institutions and Individual Fellowships at Federal and Foreign Institutions to PMS subaccounts.

Background
Most payments for NIH domestic awards are currently made via pooled accounts in PMS, which is a centralized grants payment and cash management system operated by the Division of Payment Management (DPM) HHS.

Payments for NIH awards to Federal institutions, Federal Fellows and Foreign Fellows are currently made directly by the Office of Financial Management (OFM), NIH.

Revised Implementation Timeline
The transition of all NIH awards to PMS subaccounts is anticipated to take place in FY14 and FY15.

FY2014 Implementation Plans for Awards with New Document Numbers
Between October 1, 2013 and September 30, 2014, NIH will transition payment for all domestic awards with new document numbers (i.e., Type 1, Type 2, Type 4, Type 6, Type 7, and Type 9) from PMS pooled accounts (G accounts) to PMS subaccounts (P subaccounts). For these types of awards, PMS will establish subaccounts for each NIH award made on or after October 1, 2013. All subsequent non-competing continuation awards will be issued in subaccounts.

Anticipated Implementation Plans in FY2014 and FY2015 for Type 3 Awards
Please be aware that competitive revisions/supplements (Type 3s) issued to domestic awards in FY 2014 and FY 2015, will be issued in the same account as the parent award. If the parent award is in the pooled account at the time the Type 3 is issued, the Type 3 will be in the pooled account too. If the parent award was issued in a P subaccount at the time the Type 3 is issued, the Type 3 will also be in the P subaccount account.

Anticipated FY2015 Implementation Plans for All Other Domestic Awards
Between October 1, 2014 and September 30, 2015, NIH will transition payment for all continuing domestic awards (i.e., Type 5 and Type 8) awards that have not yet transitioned to subaccounts from PMS pooled accounts (G accounts) to PMS subaccounts (P subaccounts). For these types of awards, PMS will establish subaccounts for each NIH award made on or after October 1, 2014.

For domestic grants with a non-competing continuation year of funding in fiscal year (FY) 2015 (October 1, 2014 – September 30, 2015), NIH will use a technical process to shift the funding from PMS G accounts to PMS P subaccounts by issuing all FY 2015 non-competing continuation awards that have not yet transitioned to subaccounts as Type 4 awards (funded extension awards). This means that all domestic Type 5 awards (non-competing continuation awards) and Type 8 awards (non-competing continuation awards with a change of awarding Institute or Center), will be issued as Type 4s during the transition period. This enables NIH to separately track obligations and payments for grants that span the Federal FYs 2014 and 2015. In addition to changing the record Type and the document number for the FY 2015 award, NIH will change the project period end date of the FY 2014 award when the FY 2015 award is issued. The project period end date will be changed to the budget period end date. This effectively breaks the single competitive segment into two shorter "competitive segments." The change will be reflected in the eRA Commons; however, NIH will not issue a revised Notice of Award (NoA) for the FY 2014 award. Therefore, the FY 2014 award becomes the final year of the first "competitive segment" and requires final Federal Financial Report (FFR) expenditure data. If the award is under Streamlined Non-competing Award Process (SNAP), the grantee will be required to submit FFR expenditure data that covers the project period from the original start date through the new project period end date.

NIH will make this transition as seamless as possible for grantees and NIH staff. Records for non-competing continuation progress reports (Type 5s), or in rare instances Type 8s, that have not yet transitioned to subaccounts will be converted to Type 4s. The conversion will be processed internally by NIH. There will be no change to the due dates, submission, or review of progress reports for domestic awards for FY 2015.

Please see below for procedural changes in carryover of funds for non-competing continuation awards issued in FY 2015.

Change in Process to Carryover Funds and Federal Financial Reports for Domestic Non-Competing Continuation Awards during FY 2015 (October 1, 2014 – September 30, 2015).
Non-competing continuation progress reports (Type 5s), or in rare instances Type 8s, that were converted to Type 4s to accommodate the change in method of payment from the pooled accounting to subaccounts, require a final FFR for the prior year(s) of the competitive segment before any carryover funds would be available for drawdown in the PMS. However, this requirement does not change the carryover authority listed in Section III of the NoA. If the award was issued with automatic carryover authority, OFM will automatically authorize the carryover in the PMS P subaccount equal to the amount of unobligated balance reported on the FFR.* If the award was issued without carryover authority, OFM will automatically transfer the unobligated balance reported on the FFR to the PMS P subaccount; however, the grantee will still be required to submit a prior approval request to use carryover funds as detailed in the NIH Grants Policy Statement, Section 8.1.1.1. If the request is approved, a revised NoA reflecting the approved carryover amount will be issued and the authorized amount will be reflected in PMS. Failure to submit FFR expenditure data in a timely manner may affect future funding.

*In accordance with existing policy, the GMO will review unobligated balances in excess of 25 percent of the total authorized amount for the budget period and may request additional information from the grantee. If the GMO determines that some or all of the unobligated funds are not necessary to complete the project, the GMO may restrict the grantee’s authority to automatically carry over unobligated balances in the future, use the balance to reduce or offset NIH funding for a subsequent budget period, or use a combination of these actions. The GMO’s decision about the disposition of the reported unobligated balance will be reflected in the terms and conditions of the NoA.

An FFR to report expenditure information is not required for Kirschstein-NRSA individual fellowship awards.

Change in Processing of Funds Requested for Awards in PMS Subaccounts that are 90 days Beyond the Project Period End Date
When a federal grant expires, recipients can only use remaining grant funds to liquidate expenses incurred during the performance period. Federal grants management policy specifies that within 90 days of the project period end date the grant recipient must submit its final financial report for the grant, unless the awarding agency extends the project period end date or the reporting period due date. See NIH Grants Policy Statement Section 8.6 for more information on the grantee responsibilities for timely closeout is a grantee responsibility.

In an effort to promote more timely financial closeout of awards, PMS will now hold payment requests for funds in subaccounts for awards that are 90 days or more beyond the project period end date. Funds requests for these awards will not be processed unless, and until, the awarding Agency has approved the payment request.

Frequently Asked Questions
NIH will post answers to frequently asked questions on the transition to PMS subaccounts on the following site: http://grants.nih.gov/grants/frequent_questions.htm under the Other Policies/Resource heading, Payment (PMS Subaccounts).

Inquiries

Please direct all inquiries to:

Division of Grants Policy
Office of Policy for Extramural Research Administration
Office of Extramural Research
National Institutes of Health
Telephone: 301-435-0949
Email: GrantsPolicy@od.nih.gov